Tag Archives: department of the treasury

On December 23, 2024, we learned that Beneficial Ownership Information (BOI) reporting WOULD be required, albeit later than originally planned.

The next day, December 24, I wrote a Bredemarket blog post about this.

Two days later, December 26, my December 24 blog post was already outdated. 

“On December 26, 2024, a different panel from the Fifth Circuit issued an order that vacated the court’s prior December 23 order granting a stay of the preliminary injunction. As a result, the injunction issued in Texas Top Cop Shop remains in effect nationwide and reporting companies are currently not required to file beneficial ownership information with FinCEN.”

The notice above was published on January 4.

Check back on January 6.

Beneficial Ownership Information alert. From Proskauer:

“On December 23, 2024, the Fifth Circuit of the United States Court of Appeals (the “Fifth Circuit”) issued an order that has the effect of reinstituting the deadlines under the Corporate Transparency Act (the (“CTA”)….

“The CTA requires a range of entities, primarily smaller, otherwise unregulated companies, to file a report with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) identifying the entities’ beneficial owners—the persons who ultimately own or control the company—and provide similar identifying information about the persons who formed the entity.

“FinCEN has recognized that the timing of the order lifting the injunction may be particularly burdensome and has extended the reporting deadlines.  Accordingly, reporting companies created prior to January 1, 2024, that are not eligible for an exemption, are required to file beneficial ownership reports by January 13, 2025 (and not January 1, 2025).”